Regulatory Open Forum

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  • 1.  YEAR OF THE REGULATORY WATCHCAT

    Posted 02-Feb-2020 20:38

    Short of institutionalization, incarceration or interment (anyone want to start a betting pool?), 2020 will be the year that the Regulatory Watchcat finally comes into its own.  This little hobby will probably get its own website, although that's not a burning priority for me, and I will start to actively pursue some projects instead of mostly reacting in horror.

    I have no lack of projects to choose from, so I thought I might post a list in some forums and see if anyone had any opinions regarding which of these might be of particular interest to them:

    1. Estimate the average cost of developing a 510(k) device from prototype to product.

    2. Determine whether CDRH can connect the dots between the devices it reviews premarket, the data that are submitted to support them, and the devices that are marketed post-whatever. Then, if it looks like it can, whether it does.

    3. Estimate the percentage of medical device startups that "fail." (Has anyone here ever seen a primary source for any of the numbers that get bandied about on the internet?)

    4. Evaluate the quality of CDRH decision summaries from a perspective of meaningful transparency.


    All of these projects are time-intensive and I have several other projects that are already priorities, including my De novo watch, so no one should be holding their breath that I will complete any of these projects next year.   At best, I think I will get a decent start on at least two of them.



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------


  • 2.  RE: YEAR OF THE REGULATORY WATCHCAT

    Posted 03-Feb-2020 09:42
    I like #1 & #4 (pretty sure I already know they can't do #2 based on personal experience). I suspect #1 will be really complicated though, given breadth of devices in that category. I would tend to think life supporting, life sustaining devices would skew well upward from others.

    g-
    ​​​​

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    Ginger Glaser RAC
    Chief Technology Officer
    MN
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  • 3.  RE: YEAR OF THE REGULATORY WATCHCAT

    Posted 03-Feb-2020 11:15
    Edited by Julie Omohundro 14-Dec-2020 13:39
    Based on my own experience and that of others, I can assure you that your experience with #2 is not limited to your tidepool. :)  Unfortunately (from my perspective), I think I'm likely to find that it not only can't connect the dots, but that it is oblivious to the notion that there are dots, and that these dots not only can be connected, and that connecting them is the whole point. IMO. 

    I'm afraid the results of #4 are not going to be pretty for anybody, CDRH or industry...


  • 4.  RE: YEAR OF THE REGULATORY WATCHCAT

    Posted 14-Dec-2020 08:40
    Edited by Julie Omohundro 14-Dec-2020 13:43

    UPDATED 12/2020:

    Everyone has their "This was the year I was going to…" stories.  This one is mine. I had to chuckle when I re-read the first sentence of my post last February.  Apparently I overlooked a fourth option, oops.

    The last sentence made me laugh darkly, as I ended up mostly reacting in horror to, among other things, pretty much everything going on at FDA this year.

    That said, contrary to how it must have seemed to those of you who are Connected with or Following me on LinkedIn, I haven't actually spent the entire pandemic ranting there.  I was concurrently engaged in a long slow chug through the De novo biocompatibility data.  Through, and through, and through again.  First an endless number of passes to identify the different types of information available and figure out how to organize it in some useful way.  Then over and over again, each time pulling some information and being stumped by other information.  Surprisingly, not all of the summaries are a shining tribute to superb writing skills, heh.

    After all that…well, it's a start.

    And a stop, at least for now.  I am not at all ready to tackle the 510(k) and PMA biocompatibility sections for comparison to the De novo.  And, on the whole, I think I've had enough of the De novo for a while.  Sometime in the first two quarters of next year, I might tackle software, which I'm expecting to be pretty straightforward (heh), but if it isn't, I'll put it off for another day. Or year.

    For now, I'm planning to write up the biocompatibility information data I was able to compile this year, as the fourth installment of my neverending De novo analysis.  I am aiming to post it to the forum before my RAPS membership expires on Saturday.



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 5.  RE: YEAR OF THE REGULATORY WATCHCAT

    Posted 21-Dec-2020 08:42

    On further thought, I realized the best I could do by today was a preliminary draft of the De novo biocompatibility data.  I won't be around to update it, nor to delete it, and I decided I didn't want to leave a preliminary draft posted here in perpetuity, so I decided against posting it here after all



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 6.  RE: YEAR OF THE REGULATORY WATCHCAT

    Posted 15-Dec-2020 12:18
    Edited by Julie Omohundro 18-Dec-2020 18:52

    NEW PLAN FOR 2021:

    My plan for this past year was to summarize the biocompatibility data, update some of the earlier data on De novo timeframes, do a slice and dice on a journal article and an industry report, and then roll out my Regulatory Watchcat website.   I expect to get to the rest of this in the first quarter of the coming year…unless life gets in the way again, which it has a habit of doing.

    I will also be putting in some time on a new project, courtesy of the pandemic.  Now that I've gotten a handle on the ethical aspects of EUA products, I'm sticking with it.  Those dismal fact sheets have got to go.

    By second quarter, I hope to pick up the project that seemed to be of most interest to my RA colleagues and to others in and around the medical device industry:

    1. Estimate the average cost of developing a 510(k) device from prototype to product.

    Anyone who is interested in seeing the results…whenever, can find them posted under my profile on LinkedIn.  I also maintain a Watchcat distribution list, but maintain it is about all I've done.  It's currently has low visibility. It will have a bit more visibility once the Watchcat has its own website.



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------